TaxTMI 
TaxTMI 
2025 (8) TMI 537
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.... referred to as "BMA"] for AY 2019-20. 2. The assessee has raised the following grounds in the appeal: "1. On the facts and in the circumstances of the case, the Appellant submits that the Hon'ble Commissioner of Income Tax (Appeals) erred in upholding the deposits of 200,912.11 Euros (Equivalent to INR 1,62,26,345) received from RGN Trust as the value of undisclosed foreign assets, without appreciating that the said amount was received as inheritance from the Appellant's late uncle Dr Rusi D Motashaw, duly supported by documentary evidence including the trust deed and correspondence from the trustees on the ground that the Appellant failed to establish a direct and verifiable link between the Inheritance claim and the f....
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....erred by the Appellant's son Cyrus Motashaw from his verifiable bank account, out of funds refunded from a failed investment in BTS Fund, duly supported by email correspondence and bank records on the ground that the Appellant failed to provide conclusive evidence to establish the legitimacy of the credit in the bank account of his son. The Appellant submits that the receipt of funds of GBP 64,000 (Equivalent to INR 59.06,214) be not treated as undisclosed foreign assets and income and the same be reduced from the assessed income. 4. On the facts and in the circumstances of the case, the Appellant submits that the Hon'ble Commissioner of Income Tax (Appeals) erred in confirming the addition in respect of the deposi....
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....(Appeals) erred in confirming the value in foreign bank accounts which were already closed prior to the previous year 2018-19, as undisclosed assets located outside India despite the fact that they were not assets held during the year under consideration and are outside the purview of taxation under the BMA for AY 2019-20. The Appellant submits that the abovementioned foreign bank accounts be not treated as undisclosed assets located outside India and the value of same should be reduced from assessed income. 7. On the facts and in the circumstances of the case, the Appellant submits that the Hon'ble Commissioner of Income Tax (Appeals) erred in confirming the inclusion of foreign income earned prior to AY 2016-17 as un....
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....nd Tax Resident of India. Information was received regarding ownership of undisclosed foreign bank accounts by the assessee. It was further noticed that the assessee was associated with foreign bank accounts in the United Kingdom. The assessee has been a non-filer since AY 2001-02 and has, thus, not disclosed these bank accounts to the Indian income tax authorities as required by law. The Finance Act, 2012 has made it mandatory to file information relating to asset located outside India in the income tax return. 3.2. In view of the above facts, a search action u/s. 132 of the Act was conducted on 27.06.2018 in the case of assessee. Thereafter, an order u/s. 10 of the Black Money Act, (BMA) was passed by the DDIT (Inv.), Mumbai (AO) on 27....